I. Core Objective
The sandbox regulatory system creates a “safe testing ground” before products enter the market. It involves trial manufacturing and usage, technical evaluations, and risk assessments, all within a controlled environment. The goal is to identify and eliminate quality and safety hazards in advance, ensuring the safe and feasible application of “Three New” technologies.
II. Scope and Eligibility
The system applies to special equipment using “Three New” technologies that either conflict with existing safety technical specifications or are not yet regulated but may significantly impact safety performance. Eligible applicants must be manufacturers with the required production licenses. Applications may be submitted independently or jointly with other entities such as material suppliers, designers, or installers.
III. Workflow
The sandbox regulatory process includes six steps: application, conformity review, sandbox testing, technical evaluation, license approval, and exit/termination. A central component is the sandbox testing phase, during which “Three New” products undergo real-world trials within designated periods and locations to uncover hidden risks and refine designs.
Applicants must submit a detailed testing plan, including safety measures, risk control indicators, and exit conditions, which must pass expert review before implementation. Trials typically last 24 months and may extend to a maximum of 36 months. The Recall Center provides technical support and tracking, while local regulatory departments conduct on-site inspections.
IV. Exit Mechanisms and Responsibilities
If the product fails to meet expectations, presents major hazards, or causes accidents, the test must be terminated, and the product recalled. A final “exit review” is mandatory to leave the sandbox and proceed to licensing. If the review fails, market entry will be denied. Applicants bear full responsibility for the safety and quality of trial products and are subject to legal consequences for any violations.
V. Organizational and Support Mechanisms
The SAMR’s Special Equipment Bureau oversees the system’s implementation and has issued a supporting implementation plan. The Technical Committee for Special Equipment Safety and Energy Efficiency (Anjiwei) and the Recall Center are responsible for technical evaluations and daily support. The system encourages research institutes and third parties to participate in evaluation, monitoring, and risk analysis. Information sharing is emphasized to ensure transparency and efficiency.
VI. Regulatory Principles
The system adheres to the principles of "inclusive and prudent" regulation. It provides room for innovation while setting safety boundaries to isolate risks within the sandbox. All participants must observe strict professional discipline and confidentiality. Unauthorized fees or disclosure of trade secrets are prohibited to ensure fairness and transparency in the regulatory process.
Implications for Foreign Special Equipment Manufacturers and Foreign-Invested Enterprises in China
I. Opportunities
1. Legal testing channel for “Three New” technologies
The sandbox offers a compliant pathway for new technologies not yet covered by Chinese standards.
Foreign manufacturers can test their innovations in China and lay the groundwork for future market entry.
2. Potential to influence Chinese standards
If sandbox-tested products perform well, they may promote the inclusion of related technologies in Chinese technical standards, supporting localization of international advanced technologies.
3. Strengthened cooperation with Chinese institutions
Foreign firms will collaborate with local testing and R&D institutions during sandbox testing, fostering deeper ties with China's technical community and increasing local visibility.
II. Challenges and Requirements
1. Increased compliance burden
The process involves extensive documentation, technical reviews, and expert assessments.
Foreign companies must invest in understanding Chinese regulations and may need local consultants or joint applications with Chinese entities.
2. Intellectual property risks
Technical disclosures during evaluations may pose IP risks. Despite confidentiality clauses, companies should proactively secure NDAs and safeguard sensitive data.
3. High unpredictability
The system allows for dynamic assessments and early terminations, adding uncertainty to technology promotion and business planning.
4. Product liability insurance pressure
Companies are encouraged to purchase liability insurance for trial products, increasing costs, especially for firms without a local entity in China.
III. Advantages for Foreign-Invested Enterprises in China
Compared to overseas manufacturers, foreign-invested enterprises with local operations have stronger resource coordination capabilities and are more likely to meet licensing or testing requirements.
These companies can use the sandbox system to locally validate mature overseas products, shortening time to market and building a reputation for localized innovation.”